Machinery harmonised standards: the list is repealed on 20 January 2027

If you are designing today a machine you will place on the market after 20 January 2027, the list your engineering office is copying standard references from ceases to exist that day. A decision published on 7 September says so. And the list meant to take its place, as we write, does not show up as published.

Commission Implementing Decision (EU) 2026/2015 of 4 September 2026, out in the Official Journal of the European Union, L series, on 7 September, does two opposite things: it lengthens the list of harmonised standards drafted in support of Machinery Directive 2006/42/EC, then repeals it.

Sixty-seven rows and a hundred and thirty-five days

The Annex amends Annex I to Implementing Decision (EU) 2023/1586, which is the list. We counted the rows ourselves: four inserted “in Part Two, point 2”, the cross-cutting type-B standards, and sixty-three in Part Three, point 2, letter (a), the type-C standards, machine by machine; plus two rows replaced, 401a and 457a, to carry over two corrigenda.

The first new row is numbered ‘32a.’ and reads “EN ISO 3744:2026”, with the title the Annex gives it: “Acoustics – Determination of sound power levels of noise sources using sound pressure – Engineering methods for an essentially free field over a reflecting plane […]”. Behind it come industrial robots, press brakes, grinding machines, tower cranes. The text of these standards is paywalled and we have not read it: number, title and edition are reported as they appear in the Annex, a public source.

Then Article 2, one line: “Implementing Decision (EU) 2023/1586 is repealed with effect from 20 January 2027.” And the Decision “shall enter into force on the day of its publication”: a hundred and thirty-five days separate the two dates. Recital (14) explains why: the Directive is repealed by Regulation (EU) 2023/1230 with effect from 20 January 2027, so “it is necessary to repeal, with effect from that date, Implementing Decision (EU) 2023/1586”. The list dies with the Directive it served. We have already written about a single row of that list: it now has an expiry date.

The list meant to replace it does not, today, show up

Regulation (EU) 2023/1230 ties the presumption of conformity to one condition only: Article 20(1) grants it to products conforming to harmonised standards “the references of which have been published in the Official Journal of the European Union” — published, that is, in support of the Regulation.

We looked for that publication, and state method and limit. Two queries against the Cellar SPARQL endpoint over the titles of acts in English, for “2023/1230” and for “harmonised standards for machinery”. The second returns twenty-three acts, all “in support of Directive 2006/42/EC”, and includes the decision of 4 September: the database is current, not an empty result set. No act shows up as adopted in support of the Regulation. The limit: a search on titles cannot see an act titled differently from both strings. The independent check is the Commission’s page on harmonised standards for machinery, which today carries an explicit notice: “a new Commission Implementing Decision with the list of harmonised standards under the new Machinery Regulation is being prepared […]. The first Machinery Regulation list can be expected before the end of this year”. We are not writing that nothing has been published: we are writing that, on this search, nothing shows up.

What is still standing on 21 January

The transitional provisions protect less than people believe. Article 52(1) of the consolidated text provides that Member States “shall not impede the making available on the market of products which were placed on the market in conformity with Directive 2006/42/EC before” 20 January 2027. It protects products already placed: the machine that left your shop floor on 19 January keeps circulating. It says nothing about the presumption of conformity of the machine you place on the market on the 21st.

Paragraph 2 saves something else, and it is worth money: “EC type-examination certificates and approval decisions issued in accordance with Article 12 of Directive 2006/42/EC shall remain valid until they expire.” Whoever has already paid a notified body does not pay twice.

What stays exposed is the part that costs most to redo. Annex IV requires the technical file to state “the references of the harmonised standards referred to in Article 20(1)” — the Regulation’s ones — and Annex V requires the EU declaration of conformity to state “the date of the publication of the reference to harmonised standards in the Official Journal of the European Union”: a date that does not exist today. The same holds for anyone counting on the transitional presumption for high-risk AI on board a machine: same Article 20, same precondition.

The valve exists, but it only opens in an emergency

There is a way out for when harmonised standards are missing, and it is not the one people hope for. Article 25d — introduced by Regulation (EU) 2024/2748, marked ▼M1 in the consolidated text — empowers the Commission to list appropriate standards or establish common specifications, but only “Where machinery or related products have been designated as crisis-relevant goods”. Article 25a sets three cumulative conditions: a Commission implementing act, that designation, and the internal market emergency mode activated. None of them describes an ordinary January for a machine builder. There is also the general route of Article 20(3), but it is conditional on the failure of the standardisation request made to the European standardisation bodies: while that work runs to schedule, it does not open.

Why a closed system, drawn from this case

The technical file is not paperwork: it is the most confidential corpus a machine builder owns. Annex IV asks for “design and manufacturing drawings and schemes of the machinery or related product and of its components, sub-assemblies and circuits”; Article 10(3) adds that “the source code or the programming logic included in the technical documentation” must be made available to the authorities upon a reasoned request, for at least 10 years after the product is placed on the market. Ten years in which it must remain readable as of the date the design decision was taken, against the list in force that day, not today’s. And when the footing shifts, one question needs a fast answer: which machines and which files rest on which standards. Dated memory and instant interrogation ask the same thing: that drawings, control logic and calculations stay in an environment of yours, where no outside supplier reads what you have designed.

On the comply axis, it becomes a check running on your own documents: every file tied to the references it cites, with each reference’s Official Journal publication date, and an alert when a row changes number or legal basis, with the audit trail to show the notified body. On the decide axis, the same system holds together in one operational model the technical file, the register of machines sold, the notified body’s certificates and the monitoring of the Official Journal; on that model, AI agents run the routine checks with one of your engineers in command. It holds for manufacturing as much as for defence, government and healthcare. We deliver it on-premise, on self-contained machines that need no deep integration into your network, or on our dedicated cloud, with the data centre in Italy and premises we staff ourselves, always with shared management: you should not already need someone in-house to run AI models.

Do you know how many of your machines in production have a file citing the list now being repealed? A check with one of our engineers tells you in an afternoon.

Sources

What we do not know

The first limit is the method by which we searched for an absence: a title search on Cellar cannot see an act containing neither “2023/1230” nor “harmonised standards for machinery”, and the Commission notice is current as of when we read it, with no revision date on the page. We do not know when the new list comes out: expected before the end of this year is not a date, and the margin to 20 January 2027 can shrink to a few weeks. We do not know which rows it will contain: the Commission announces the vast majority of those cited today, but publishes no named list. And we do not know how a notified body will treat a file handed in inside that window: it has not happened often enough for a precedent.